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Investigation and Response
APPENDIX 3-V: Sample Key Allegations Worksheet
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Table of Contents
- Front Matter
- Chapter 1: Overview of Compliance and Ethics Practice
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Chapter 2: Foundational Materials and Program Infrastructure
- Essential Elements of an Effective Ethics and Compliance Program
- APPENDIX 2-A: Sample Letter to Vendors
- APPENDIX 2-B: Sample Nonretaliation/Nonretribution Policy
- APPENDIX 2-C: Sample Compliance Officer Job Description
- APPENDIX 2-D: Sample Audit Review Form
- APPENDIX 2-E: Sample Confidentiality Statement
- APPENDIX 2-F: Sample Hotline Information Sheet
- APPENDIX 2-G: Sample Compliance Issue Follow-Up Form
- APPENDIX 2-H: Glossary of Compliance-Related Terms
- The History of the Organizational Sentencing Guidelines and the Emergence of Effective Compliance and Ethics Programs
- Beyond the Sentencing Guidelines: Governing Directives, Guidelines, and Standards from around the World
- Components of an Effective Compliance and Ethics Program
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Chapter 3: Implementing a Program
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Getting Started
- Initial Steps for Building a Program
- APPENDIX 3-A: Compliance Program Implementation Action Plan
- APPENDIX 3-B: Compliance Job Description
- APPENDIX 3-C: Compliance Program Risk Inventory
- APPENDIX 3-D: Sample Compliance Committee Charters
- APPENDIX 3-E: Sample Policies and Procedures
- Making the Business Case: Selling Compliance and Ethics to Management
- Appendix 3-F: Benefits of a Compliance Program
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Compliance Standards and Procedures
- Creating a Code of Conduct
- Communicating Values Across Cultures: Globalizing Your Code Of Ethics
- APPENDIX 3-G: General Checklist for Global Code Implementation
- Developing and Implementing Policies for an Effective Program
- APPENDIX 3-H: Sample Policy Prioritization Matrix
- APPENDIX 3-I: Sample Policy Development Workflow
- APPENDIX 3-J: Sample Policy Template
- APPENDIX 3-K: Sample Policy Implementation Master Tracker
- APPENDIX 3-L: Sample Communication Plan
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Program Oversight and Management
- Structuring the Chief Ethics and Compliance Officer and Compliance Function for Success: Six Essential Features of an Effective CECO Position and the Emergence of the Modern Compliance 2.0 Model
- Board Engagement, Training and Reporting: Strategies for the Chief Ethics and Compliance Officer
- APPENDIX 3-M: Twenty Questions that Boards of Directors Should Ask about Compliance and Ethics*
- APPENDIX 3-N: Web Conference: Not Your Father’s Board Training
- APPENDIX 3-O: Web Conference Q&A: Not Your Father’s Board Training
- YES—A Board can Positively Affect Culture: 10 Practical Actions
- Delegation of Authority
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Education and Awareness
- Essential Steps for Ethics and Compliance Program Branding and Marketing
- APPENDIX 3-P: Branding and Marketing Resources
- Training by Design
- The Effectiveness of Compliance Training
- Fraud Awareness Training: Enhancing a Low Cost, High Impact Control in Challenging Economic Times
- 3M’s Transparency Journey: Using Ethics and Compliance Cases as Teaching Tools
- Onboarding as a Key to an Effective Compliance Program
- Auditing and Monitoring
- Internal Reporting Systems
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Investigation and Response
- Creating an Organizational Investigations Program and Conducting Effective Workplace Investigations
- APPENDIX 3-R: Checklist for Assessing Investigation Capabilities
- APPENDIX 3-S: Sample Internal Investigations Policy
- APPENDIX 3-T: Sample Upjohn Warning
- APPENDIX 3-U: Sample Evidence Collection Worksheet
- APPENDIX 3-V: Sample Key Allegations Worksheet
- APPENDIX 3-W: Key Facts Worksheet
- APPENDIX 3-X: Sample Investigation Report Form 1
- APPENDIX 3-Y: Sample Investigation Report Form 2
- APPENDIX 3-Z: Sample Policy Against Retaliation
- APPENDIX 3-AA: Instructions to Witnesses
- Independent Investigations Overseen by the Audit Committee: Procedures and Guidance
- Root Cause Analysis: A Critical Ethics and Compliance Practice
- Taking a Broader View of Compliance Risks and Enforcement Readiness: Tips on Maintaining Good Regulatory Relationships, and Preparing for Grand Jury Subpoenas and Search Warrants
- Discipline and Incentives
- Risk Assessment and Management
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Getting Started
- Chapter 4: Measuring Effectiveness
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Chapter 5: Specific Compliance and Ethics Risks
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Anti-Corruption and Anti-Bribery
- Anti-Corruption and Anti-Bribery Compliance Programs
- APPENDIX 5-A: Additional Resources on Anti-Corruption and Anti-Bribery
- APPENDIX 5-B: Considerations in Initially Planning or Reviewing Your Training Program
- APPENDIX 5-C: Checklist for Managing Third-Party Risk
- APPENDIX 5-D: Common Red Flags Indicating Heightened Potential for Corruption
- The UK Bribery Act 2010
- APPENDIX 5-E: Bribery Act Resources
- International Recognition for Compliance and Ethics Programs: The 2010 OECD Good Practice Guidance on Internal Controls, Ethics and Compliance
- A Global Standard to Address Bribery Risk: ISO 37001: Anti-Bribery Management Systems Standard
- Anti-corruption Laws/Regulations in Latin America
- APPENDIX 5-F: Latin America Anti-corruption Resources
- Anti-Money Laundering
- Antitrust/Competition Law
- Conflicts of Interest
- Entity-Specific Risk Management
- Environmental Liabilities
- Government Contracting and Relationships
- Government Enforcement Actions and Disclosures
- Identity Verification
- Labor/Employment
- Mergers and Acquisitions
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Privacy and Data Protection
- A Data Privacy Compliance Program Primer: A Snapshot of Data Privacy Regulations, Risks, and Compliance Program Effectiveness Strategies
- Does GDPR Apply to My Organization?
- The Role of the Data Protection Officer in Europe
- A New Decade in Data Privacy: Complying with the CCPA
- Bring Your Own Device Policies and Practices
- Cybervigilance and Cyber-resiliency
- Cyber Insurance Guidelines for Corporate Compliance and Ethics Executives and Boards of Directors
- APPENDIX 5-L: Determining your Company’s Cyber Insurance Needs
- APPENDIX 5-M: How to Prepare for and Reduce Costs for Cyber Insurance
- APPENDIX 5-N: Common Cyber Insurance Mistakes to Avoid
- Data Mapping: A Necessary Risk Management Tool for Simplifying Data Compliance
- APPENDIX 5-O: Typical Data Map
- APPENDIX 5-P: Data Map Survey Worksheet
- Security Incident and Data Breach Response
- Records Management and Retention
- Social Media
- Supply Chain
- Technology and Compliance
- Trade Compliance
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Anti-Corruption and Anti-Bribery